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2010 (7) TMI 562 - AT - Income TaxSubscription income or royalty – DTAA between India and Ireland - In the case of WIPRO vs ITO (2004 -TMI - 57806 - ITAT BANGALORE-B) wherein a similar subscription received by the assessee from WIPRO Ltd. under identical service agreement was held to be not chargeable to tax in India by the Tribunal after rejecting all the contentions raised on behalf of the Revenue in support of its stand that the said amount was chargeable to tax in India – Held that the subscription income received by the assessee from the Indian clients was not in the nature of royalty taxable in India – Appeal is allowed
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